Modern slavery act

Introduction

This statement sets out the actions of Sepura Plc ("Sepura" or "the Company") to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. The Company aims to ensure that its business operates in an open and transparent way and its approach to tackling modern slavery throughout its supply chains is consistent with its obligations under the Modern Slavery Act 2015.

Organisational Structure

This statement covers the activities of Sepura which designs, manufactures and supplies digital radio products and solutions for mission critical communications. Founded in the UK in 2002, Sepura was acquired by Hytera Communications Corporation Limited ("Hytera") in May 2017. Sepura operates throughout the world in conjunction with other members of the Hytera group of companies and a network of regional partners who sell and provide local support for its products.

Our Supply Chain

Sepura's principal activities are designing, manufacturing and supplying digital radio products and solutions. Sepura's Supplier Selection and Approval Policy has been updated and details how it its supply chain is managed and how all of its suppliers must undergo an approval process to ensure compliance.

Responsibility

The Chief Executive Officer has responsibility for the implementation of the Company's anti-slavery initiatives and on-going review of their application and effectiveness.

Actions taken to safeguard against Slavery and Human Trafficking:

Health and Wellbeing Policy

Sepura has a responsibility to ensure that working conditions and all work activities and locations are free from avoidable risk to the health of its employees. This policy is designed to ensure compliance with the Equality Act 2010, the EHRC Employment Statutory Code of Practice, the Protection from Harassment Act 1997 and the Modern Slavery Act 2015.

Sepura recognises the benefits of good health and will:

  • monitor and prevent the occurrence of any work-related disease
  • provide working conditions which are healthy and comfortable
  • encourage a culture where managers take an active interest in the health and well-being of their staff
  • seek the early identification and management of work-related ill health
  • enable employees to raise, discuss and resolve individual work related ill health issues through the involvement of and consultation with an occupational health provider

Equal opportunities and Dignity at Work Policy

Sepura will take all reasonable steps to provide a work environment in which all employees are treated with respect and dignity and that is free from harassment.

Any form of harassment, whether engaged in by employees or by outside third parties who do business with the Company, such as clients, customers, contractors and suppliers, will not be condoned or tolerated. The Company will take appropriate action against any third parties who are found to have committed an act of improper or unlawful harassment against its employees, including slavery or human trafficking.

Supplier Assessments

Individual supplier assessments will be carried out to procure adherence to satisfactory working conditions prior to entering into contractual commitments. Each supplier is assessed to ensure adherence to the Modern Slavery Act 2015 as part of our Supplier Visit Assessment Reports and Supplier Qualification Questionnaires.

Recruitment

All relevant pre-employment checks will be undertaken prior to staff being employed and the Company will carry out fair and transparent recruitment processes. The Company also requires any recruitment agencies acting on its behalf to commit to the principles of fair and transparent recruitment in the provision of agency staff.

The Company is committed to equal pay in employment. In order to achieve this, Sepura will endeavour to maintain a pay system that is free from bias and based on objective criteria.

Safeguarding

The Company will raise and maintain staff awareness of the risks of slavery and human trafficking. It remains committed to the highest standards of quality, openness and accountability and as part of this commitment provides a confidential reporting process for employees to report serious concerns about any aspect of the Company's activities which includes abuse or neglect of vulnerable people. The reporting of any wrongdoing is encouraged through internal and external whistleblowing procedures, and the Company will protect whistleblowers.

Statement Approval

This statement has been approved by the Board of Sepura who will ensure it is reviewed and updated annually.

Steve Barber

Acting CEO

August 2018

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